1. Introduction
Colabor is committed to maintaining the accuracy, security and privacy of personal information in accordance with applicable laws. This Privacy Policy is a statement of principles and guidelines for the protection of personal information of our Web site visitors, customers, personnel, service providers and other individuals. The objective of Colabor Privacy Policy is to ensure responsible practices in the collection, use and disclosure of personal information, in accordance with applicable legislation.
This Privacy Policy applies to Colabor and its personnel and agents. Colabor does not include resellers or distributors of Colabor products and services. For the purposes of this Privacy Policy, “affiliates” means the parent company, subsidiaries and affiliated companies of Colabor, as they may exist from time to time.
In addition to this Privacy Policy, Colabor may also be subject to the requirements of applicable legislation and regulations and the orders of any court, regulatory body or other lawful authority.
2. Personal Information
Personal information is information about an identifiable individual. Personal information does not include aggregated information that does not allow an individual to be identified. An individual’s business contact information, such as his or her name, title, business address, business telephone and business facsimile numbers, are not considered to be personal information.
3. Privacy Principles
The following are the ten privacy principles forming this Privacy Policy.
Principle 1 – Accountability
Colabor is responsible for personal information under its control and will designate one or more persons who are accountable for Colabor’s compliance with the following principles.
Principle 2 – Identifying Purposes for Collection of Personal Information
Colabor will identify the purposes for which personal information is collected at or before the time the personal information is collected. Some of the identified purposes for which Colabor collects, uses or discloses of personal information are described in Section 4 below.
Principle 3 – Obtaining Consent for Collection, Use or Disclosure of Personal Information
The knowledge and consent of an individual are required for the collection, use, or disclosure of his or her personal information, except where inappropriate or as permitted by law. In obtaining consent, Colabor will use reasonable efforts to ensure that an individual is advised of the identified purposes for which personal information will be used or disclosed. In determining the appropriate form of consent, Colabor will take into account the sensitivity of the personal information and the reasonable expectations of a reasonable person. Consent will not be obtained through deception. An individual may withdraw consent at any time, subject to legal or contractual restrictions and reasonable notice. Colabor will advise the individual of the implications of such withdrawal.
Principle 4 – Limiting Collection of Personal Information
Colabor will limit the collection of personal information, both the amount and the type of information, to that which is necessary for the purposes identified by Colabor. Personal information will be collected by fair and lawful means, and not by misleading or deceiving individuals about the purpose for which information is being collected.
Principle 5 – Limiting Use, Disclosure, and Retention of Personal Information
Colabor will not use or disclose personal information for purposes other than the identified purposes for which it was collected, except with the consent of the individual or as required or permitted by law. Colabor will retain personal information only as long as necessary to fulfill the identified purposes.
Principle 6 – Accuracy of Personal Information
Personal information will be as accurate, complete and up-to-date as is necessary for the purposes for which it is to be used. Colabor will update personal information about individuals as necessary to fulfill the identified purposes or upon notification by the subject individual. Colabor will not routinely update personal information, unless such process is necessary to fulfill the identified purposes.
Principle 7 – Security Safeguards
Colabor will protect personal information by security safeguards appropriate to the sensitivity of the information. Colabor will use reasonable efforts and security measures to protect personal information against loss or theft, as well as unauthorized access, disclosure, copying, use, modification, disposal or destruction. Colabor will protect personal information disclosed to third parties by contractual agreements stipulating the confidentiality of the information and the limited purposes for which it is to be used.
Principle 8 – Individual Access to Personal Information
Colabor will inform the individual of the existence, use, and disclosure of his or her personal information and, subject to certain exceptions, will give the individual access to that information. If access is denied, Colabor will notify the requesting individual in writing, give reasons for the denial, and inform the individual of the recourses open to him or her. If access is granted, Colabor will give the requesting individual a reasonable opportunity to consult the personal information collected by Colabor. Personal information will be provided in an understandable form within a reasonable time, generally within 30 days, and at minimal cost to the individual. Colabor may extend such 30 day period by up to an additional 30 days if meeting the time limit would unreasonably interfere with the activities of Colabor or the time required to undertake any consultations necessary to respond to the request would make the time limit impracticable to meet. An individual will be able to challenge the accuracy and completeness of the information and have it amended as appropriate.
Principle 9 – Challenging Compliance
An individual will be able to address a challenge concerning compliance with this Privacy Policy to Colabor Privacy Officer.
4. Identified Purposes for the Collection, Use and Disclosure of Personal Information
Colabor and its agents, affiliates and service providers may collect, use or disclose your Personal Information for the following purposes:
B. to develop, publish and distribute our newsletters, press releases, marketing and advertising media, and other Colabor branded products and services, in any format or media;
C. to develop, enhance, market, sell, provide and inform you of Colabor’s products and services;
D. to manage and develop Colabor’s and its affiliates’ businesses and operations;
E. to detect and protect Colabor, its affiliates, and other third parties against error and fraud and other illegal activity, and to audit compliance with Colabor’s corporate policies and contractual obligations;
F. as permitted by, and to comply with, any legal or regulatory requirements or provisions; and
G. for any other purpose to which you consent.
Colabor may collect and use your personal information received from an organization (or its affiliate) or an individual who, in the reasonable judgment of Colabor, is providing the information as your agent, where you consent to such collection or as required or permitted by law.
Colabor may disclose your personal information to an organization (or its affiliate) or an individual who, in the reasonable judgment of Colabor, is receiving the information as your agent, where you consent to such disclosure, or as required or permitted by law, and may also disclose your personal information to an organization (or its affiliate) or an individual who has been retained by Colabor to perform functions on its behalf or to provide services to Colabor, provided such organization or individual does not collect, use or disclose the personal information for any purpose other than to perform such functions or provide services to Colabor, all where you consent to such collection or as required or permitted by law.
Consent
BY SUBMITTING PERSONAL INFORMATION TO COLABOR OR ITS AFFILIATES, SERVICE PROVIDERS AND AGENTS, YOU AGREE TO OUR COLLECTION, USE AND DISCLOSURE OF SUCH PERSONAL INFORMATION FOR THE IDENTIFIED PURPOSES DESCRIBED IN THIS PRIVACY POLICY, PROVIDED THAT SUCH COLLECTION, USE AND DISCLOSURE IS IN ACCORDANCE WITH THIS PRIVACY POLICY AND AS PERMITTED OR REQUIRED BY LAW. Subject to legal and contractual requirements, you may refuse or withdraw your consent to any one or all of the purposes described in Section 4(a), at any time with reasonable notice by contacting Colabor Privacy Officer. If you refuse or withdraw your consent, we may not be able to establish or maintain a commercial relationship or provide you or continue to provide you with some products, services or information which may be of value to you. To the extent that you provide Colabor with personal information of another person, you represent that you have the authority or have obtained all necessary consents from such person to enable Colabor to collect, use and disclose such personal information for the purposes set forth in this Privacy Policy.
5. Privacy and our Web sites
Cookies – When you access Colabor Web site, we may use a browser feature called a ‘cookie’ to collect information that is not personally identifiable (such as the type of Internet browser and operating system you use, the domain name of the Web site from which you came, number of visits, average time spent on our Web site, and pages viewed). A cookie is a small text file containing a unique identification number that identifies your browser, but not you, to our computers each time you visit one of our Web sites that uses cookies. Unless you specifically inform us, we will not know who you are. In addition to the identified purposes described in our Privacy Policy, Colabor may use this cookie information and share it with our affiliates and other organizations with whom we have a commercial relationship to measure the use of our Web sites and to improve the functionality and content of the Web sites. If you wish, you can reset your browser either to notify you when you have received a cookie or refuse to accept cookies. However, if you refuse to accept cookies, you may not be able to use certain features on our Web sites.
Online Communications – In order to provide you with a product, service or information, you may voluntarily submit personal information to us for purposes such as registering for our services, obtaining information, corresponding with us, and participating in surveys. We may combine and store personal information about your use of our Web sites and the online information you have provided with certain other online and offline information we may have collected.
E-Mail Communications – Occasionally, Colabor may send you e-mail communications with information that may be useful to you, including information about the products and services of Colabor, its affiliates and other third parties with whom we have a commercial relationship. We will include instructions on how to unsubscribe and inform us of your preferences if you decide you do not want to receive any future marketing or promotional e-mails from Colabor. However, if you are a customer, supplier or otherwise have a commercial relationship with Colabor, to ensure that you receive important information, you agree that we may send you non-marketing related information when necessary.
Links – Our Web site may contain links to other Web sites, which are provided to you as a convenience only. You are advised that other third party Web sites may have different privacy practices than Colabor, and Colabor has no responsibility for such third party Web sites.
6. Changes to this Privacy Policy
Colabor reserves the right to modify or supplement this Privacy Policy at any time. If we make any change to this Privacy Policy, we will post such changes on our Web site and they will be available upon request to Colabor Privacy Officer. However, Colabor will seek an individual’s consent if it seeks to collect, use or disclose his or her personal information for purposes other than those to which the individual has consented unless otherwise required or permitted by law.
Changes to our Privacy Policy will be noted here so that you can be fully informed about our privacy policies and practices.
Date last revised: June 2008.
7. Further Information
For more information on Colabor’s privacy practices or if you have questions or concerns about your privacy, you can contact us through info@colabor.com.
